Lesson 8 - Quality Management End of Unit SAQ

***During HACCP preparation you have established that one of your CCPs is the temperature in the pasteuriser which needs to control the hazard of food-poisoning bacteria in a bottled alcohol-free beer.

a) Discuss how you could establish the critical limits and validate and verify the CCP and critical limits.

b) Explain how the brewery laboratory and its accreditation scheme should be involved to demonstrate effectiveness either to auditors or where a due diligence defence was required.

Response:

a) There are several options for establishing critical limits. The brewery could seek the advice of industry bodies or experts. In this instance a consultant with experience of beer microbiology could be used to specify a process by which the organisms could be killed. The brewery could also check if the European Brewery Convention, American Society of Brewing Chemists, Central European Commission for Brewing Analysis, or Master Brewers Association of the Americas has any guidance on effective pasteurisation of food-poisoning bacteria. For some critical limits, a review of legislation can be undertaken but in this instance the legislation is only likely to say the beer should be free of the organisms. The most effective way of establishing these critical limits would be through experimentation. Beer could be deliberately contaminated with the organisms in question and then varying amounts of heat applied. The treated beer would then be tested for the presence of the organisms in the lab. The lower limit would be the minimum temperature at which all the organisms are killed plus a safety factor to take account of the R95 of the method, the measurement variation of thermometers, and the process capability for pasteurisation. The maximum would be the point at which the bottle integrity could be damaged by heat and pressure in the pasteuriser, again with the safety factor applied. Once established, the critical limits would need to be validated.

Validation of the CCP demonstrates that it controls the hazard. This would be undertaken by operating the process on a trial basis on contaminated beer and the beer tested for the presence of live organisms. The trial operation of the process should be representative of the process and its variation as it is operated on a day-to-day basis. The critical limit will be said to be validated if all tests for the organisms are negative for several runs so that factors like start-ups, line stoppages, and variation in the beer can be accounted for.    

Verification of the CCP is part of the verification of the HACCP system and it demonstrates that the CCP controls the hazard on an ongoing basis. This would be undertaken by continued regular analysis of the beer for the presence of the organisms. The analysis of data from the pasteurisation process for any deviations from the critical limits would also be monitored to ensure it is operating as designed. All the elements descried thus far would be recorded in the HACCP documentation as evidence that the brewery is exercising due diligence in managing the food safety hazard. 

b) The brewery lab would be involved in confirming that the temperature sensor and recording equipment on the pasteuriser were calibrated and operating correctly. As part of its accreditation, the specification, maintenance, and calibration of measuring equipment in the lab would be checked. These checks would ensure the calibration was traceable back to national or international standards. Were the lab not accredited it would be harder to argue that due diligence had been exercised as there would be less evidence that the measuring equipment used in the lab and process were effective. The lab would also carry out the testing of the beer for the presence of food-poisoning organisms. The accreditation of that lab would help to show that the results of the validation, monitoring, and verification of the CCP and HACCP system based on these tests were representative and accurate.